Transfer Pricing Times - May 2019

In the “IRS LB&I Announces Captive Services Providers Campaign” article, we discuss the IRS Large Business and International division’s release of three new compliance campaigns, focusing on a captive services providers campaign that will target foreign captive services providers for a U.S.-based service recipient.

In the “New Zealand’s Revised International Tax and Transfer Pricing Guidance” article, we review the New Zealand Inland Revenue’s final international tax and transfer pricing guidance that aims to align the OECD BEPS guidance revisions with New Zealand law.

In the “EU and Google Set Court Date on Hungary Advertisement Tax” article, we explore the European Union Court of Justice’s agreement to hear Google Ireland Limited’s appeal against a new tax imposed by Hungary that targets companies that generate revenue from advertising in the country.

In “The OECD Releases 2017 Full Version of Model Tax Convention” article, we discuss the OECD’s recent release of the full text of the 2017 Model Tax Convention on Income and on Capital, including additional information including articles, commentaries, non-member economies’ positions, recommendations of the OECD Council, and background reports.

In the “Malaysia’s Special Program for Voluntary Disclosure” article, we discuss the Inland Revenue Board of Malaysia’s introduction of voluntary disclosure of underdeclared income, overclaimed expenses, relief, deductions and rebates.

Finally, “The OECD’s Recent Efforts on Measuring and Understanding Tax Morale” article discusses the OECD’s recently released draft working paper which focuses on understanding and measuring tax morale, which refers to taxpayer perceptions and attitudes towards paying and evading taxes, from the perspective of individuals and businesses.

We hope that you will find this and future issues of Duff & Phelps' monthly transfer pricing newsletter informative and reliable.